Suchergebnisse für: `retroactive-change` (5 gefunden)

1. 13. September 2022

   No retroactive change of legal form effective for tax purpos ...

   In its ruling of 21 February 2022 (I R 13/19), the Supreme Tax Court rejected the tax office's appeal against the ruling of the Lower Saxony Tax and ruled that the (retroactive) change of legal form of a partnership into a corporation under Section 25 Sentence 1 in conjunction with Section§ Section 20 (1) Reorganisations Tax Act is prohibited for tax purposes if, at the time of the resolution to convert, the partnership changing its legal form no longer engages in a commercial activity

   Kategorien: Supreme Tax Court cases

   Schlagwörter: partnership income, Reorganisation Tax A ...
2. 12. April 2012

   Retroactive taxation of interest on refunds of non-deductibl ...

   In 2010 the Supreme Tax Court changed its position and ruled that interest on refunds of non-deductible taxes to be tax-free. In the meantime the court has again been invited to decide whether the subsequent retroactive change in law by the German tax administration to restore the old situation is in line with the constitution.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: interest, refund, Retroactive taxation, ...
3. 09. Januar 2011

   Home office costs deductible if centre of professional activ ...

   The finance ministry has issued a decree on the implementation procedures for a retrospective change in the law increasing the scope for deducting home office costs.

   Kategorien: Official Pronouncements

   Schlagwörter: deduction, Home office costs, retroactiv ...
4. 01. Dezember 2020

   Retroactive financial integration in case of change in share ...

   A continuous and retroactive financial integration is also possible where a change in shareholder takes place during the year. The Lower Tax Court of Duesseldorf held that a fiscal unity or tax consolidation group for corporation income tax may be established already for the whole year in which the exchange of shares took place. In its judgement the court disagrees with the tax authorities’ official opinion on this issue. The Supreme Tax Court is now in charge and must finally decide the dispute.

   Kategorien: Tax Court

   Schlagwörter: retroactive change, change of shareholde ...
5. 17. November 2024

   Application for transfer at book value to be made also in a ...

   In a most recent judgment, the Supreme Tax Court held that the application for maintaining the book values in accordance with Section 3 (2) sentence 1 of the German Reorganization Tax Act can be made in the notarial deed on the reorganization of which the notary sends a certified copy to the responsible tax office in accordance with § 54 para. 1 of the Income Tax Implementation Ordinance.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: Tax Book Values, restructuring, transfer ...